Draft Proceedings of the
U.S. Environmental Protection Agency's
Second Annual
National Pollution Prevention Conference
July 3O - August 2, 199O
EPA Region vm Conference Center
2nd Floor - Denver Place
999 18th Street
Denver, Colorado
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Draft Proceedings of the
U.S. Environmental Protection Agency's
Second Annual
National Pollution Prevention Conference
Table of Contents
Introduction 1
Agenda 3
Welcome-JerryKotas 7
Speech: Energy Technologies - Amory Lovins 8
Welcome and P2 Overview - Nancy Firestone 9
The Nature and Challenges of
Pollution Prevention-Hank Schilling 11
Conference Expectations - Paul Keough 12
Session: Regional Programs/Activities 13
Session: Institutionalization/Integration 19
Action Plan Developed
Speech: Coal Processes and Efficiencies - Sandy Blackstone ..22
Session: Headquarters Initiatives 24
Speech: Renewable Energy
Technologies for Electricity - Robert Stokes 28
Speech: Global Warming - Richard Anthes 29
Session: Communication Among Headquarters and Regions ... 30
Action Plan Developed
Session: Program Leveraging and Interfacing 33
Action Plan Developed
Session: State Programs (includingTribal) 35
Action Plan Developed
Session: Conference Wrap-Up 37
Executive Action Plan 40
Appendices
A. Conference Attendees
B. Directory of Pollution Prevention Contacts
G Draft Pollution Prevention Policy Statement - January 26, 1989
D. Pollution Prevention Fact Sheets
- Setting Up a Pollution Prevention Program
- EPA's Pollution Prevention Incentives for States
- Pollution Prevention Training and Education
E. U.S. EPA Pollution Prevention Information Clearinghouse (PPIC)
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Introduction
The overall purpose of the Second Annual National Pollution
Prevention Conference was to determine the pollution prevention (P2)
program's next steps in implementing P2 activities nationwide.
During the conference. Headquarters and Regional representatives
assessed and discussed current and future efforts for institutionalizing
pollution prevention practices in traditional EPA programs; developing
effective internal communications; leveraging non-EPA programs to
promote P2 activities in specific sectors; and promoting pollution
prevention in the States and Tribes.
The conference served as both an information session and as a
discussion forum for Headquarters and Regional P2 managers and staff.
Each Regional P2 program and several Headquarters offices (PPO, OW,
OPTS, OE, ORD) reviewed the current status of their programs and/or
P2 efforts and outlined future activities. In addition, the conference
organizers (Regions VIII and IX) added an educational component to
the conference by featuring guest speakers who lectured on energy
issues. The speakers covered various topics, including renewable
energy technologies, coal and energy issues, and global wanning.
On a more active note, conference participants formed small
discussion groups to brainstorm about promoting the
institutionalization of P2 in all EPA programs and about improving
communications among Headquarters and the Regions. The small
groups then joined together and developed the basis for the two action
plans concerning these issues. Conference participants also discussed
ways to most effectively leverage other groups or activities to promote
P2 and ways in which EPA can help promote State (and Tribal) P2
efforts. These discussions took place in one large group and also
resulted in action plans.
Thus, the conference enabled Headquarters and Regional P2 managers
and staff to share their experiences and ideas in a constructive
manner. Furthermore, it provided a forum in which they could
establish or enhance working relationships.
The tangible products of the conference include four individual action
plans that describe both short- and long-term actions aimed at
improving and further promoting:
Institutionalization/Integration of P2 in EPA programs,
Internal P2 communications,
Leveraging of non-EPA programs, and
State and Tribal programs.
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For each action plan, a committee composed of Headquarters and
Regional representatives was formed to take responsibility for its
further development and implementation.
These action plans have been developed through extensive
Headquarters and Regional participation and coordination and
represent a deep commitment to the P2 program and its goals.
A consolidated action plan encompassing and summarizing the four
individual action plans has also been developed. The action plans,
summaries of conference speeches, and background and supporting
materials are assembled in this final report.
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Second Annual
National Pollution Prevention Conference
July 30 - August 2, 1990
EPA Region VIII Conference Canter
2nd Hoor Denver Place
999 18th Street
Oenvw. Colorado
Agmndm
Sunday, July 29
Colorado's Rocky Mountains. Hike a mountain trail that accommodates ail levels of hiking skill.
Enjoy lush meadows, aspen groves, and wild/lowers.
Monday, July 30
9:30 am -11:00 am Tour of Solar Energy Research Institute (SERI)
11:00 am 2:00 pm Free Tune
2:00 pm - 3:30 pm Private Sector Panel Discussion (EPA Conference Center)
Chuck Bennett, Adolph Coors
Chuck Camahan, Martin Marietta
Paula McLemore, American Institute for Pollution Prevention
Bob McMuilen, Martin Marietta
Bob Pearson, Public Service Company of Colorado
5:00 pm - 6:00 pm
6:00 pm
Reception/ Registration (Embassy Suites Hotel)
Dinner (Embassy Suites Hotel, Crystal Ballroom A)
Complimentary Refreshments Available
Welcome
Jerry Kotas, Director, Pollution Prevention Division
Keynote Speaker. Amory Lovins
Founder and Co-Director of Rocky Mountain Institute
Tuesday, July 31
8:30 am - 9:30 am
Opening Remarks
James Scherer, Regional Administrator, Region
Welcome and P2 Overview
Nancy Firestone, Special Counsel to the Deputy Administrator
Pr«~eonf«r«nc« activities ( ) ar» optional
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Evolution of Pollution Prevention
Hank Schilling, Director, Office of Pollution Prevention
Conference Expectations
Paul Keough, Deputy Regional Administrator, Region I
9:30 am -11:45 am Session on REGIONAL ACTIVITIES
Lead Moderator: Paul Keough
Introduction: Why An We Here?
Regional presentations highlighting activities, success stories,
issues, or strategies of special interest to each Region.
11:45 am - 1.00 pm Lunch Break (On your awn)
1:00 pm - 3:00 pm Session on REGIONAL ACTTVmES (continued)
3:00 pm - 3:15 pm Break
3:15pm-4:45 pm Session on INSTTTIJTIONALIZATION/INTEGRATION
Moderators John Atcheson
Kevin Dick
Overview
Breakout into 3 discussion groups
5:15 pm Bus departs from Embassy Suites for dinner
6:00 pm Dinner (The Fort, Morrison, CO)
Speaker: Sandy Blackstone
Energy Minerals Economist
Professor of Law at University of Denver
Wednesday, August 1
8:30 am - 9:30 am Session on INSTmjTIONALlZATION/INTEGRATION (continued)
Reporting to Plenary Session and Session Summary
9:30 am - 9:45 am Break
« 9:45 am -11:30 am Session on HEADQUARTERS INITIATIVES
Moderators: John CTOM
Deborah Hanlon
Jerry Kotas
Hank Schilling
Greg Ondich
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Plenary Discussion
11:30am-1:00 pm
1:00 pm - 3:30 pm
3:30 pm - 3:45 pm
3:45 pm - 5:00 pm
5:00 pm
Luncheon (Embassy Suites Hotel, Crystal Ballroom B)
Spmkas: Robert Stokes, Deputy Director for Research
Solar Energy Research Institute
Dr. Richard Anthes, President
University Corporation for Atmospheric Research
Session on COMMUNICATIONS AMONG
HEADQUARTERS AND THE REGIONS
Moderators: Jerry Kotaa
Betsy Shaver
Overview
Breakout into 3 discussion groups
Reporting to Plenary Session and Session Summary
Break
Session on PROGRAM LEVERAGING AND INTERFACING
Moderators: Jim Edwards
Abby Swalne
Plenary Session
Dinner (On your awn)
Thursday, August 2
8:30 am - 9:45 am
9:45 am-10:15 am
10:15 am-10:30 am
10:30 am-12:00 pm
12.00pm
Session on STATE PROGRAMS
Moderators: Jackie Krieger
David Teeter
Overview
Plenary Session
PRO'S Energy Efficiency Video: "Negawatts"
Presenter: David Wann
Break
CONFERENCE SUMMARY:
RESULTS, IMPRESSIONS, AND EXPECTATIONS
Jerry Kotaa
Laura Yoshii
Hank Schilling
Paul Keough
Adjournment
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Conference Facilitators: Lead - Paul Keough, Region I
Breakout Groups - Amy Schwartz, Region 9
Jon Minkoff, Region 3
Dick Long, Region 8
Jim Dunn, Region 9
Notes:
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Welcome
Jerry Kotas
Director, Pollution Prevention Division
Welcome to the Second Annual National Pollution Prevention
Conference, co-sponsored by Regions VIII and IX. The extensive
Regional involvement with this conference is encouraging to us at
Headquarters; we view it as a sign of the enthusiasm and commitment
to the pollution prevention (P2) program.
As the P2 program begins to grow, we need to confront a number
issues, including the need to showcase our successes, increased focus
on implementation (versus planning) of demonstration projects, and
further enhancing our relations with other Federal agencies (energy,
agriculture, commerce), and with the regulated community.
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Speech
Energy Technologies
Amory Lovins
Founder and Co-Director, Rocky Mountain Institute
Efficient use of resources is a profitable way to prevent pollution.
Energy technologies have become less expensive and are highly
efficient. The United States would save three-quarters of the energy it
currently uses if it were to employ the most efficient technologies.
Such technologies include compact fluorescent lights, superwindows,
and super-efficient cars.
The profits from using these technologies arise from the reduction in
maintenance and operating costs and the longer-lasting nature of
these technologies (far lower replacement costs). Compared to more
prevalent, but less efficient energy technologies, these newer
technologies incur negative costs and thus yield profits.
Although these technologies yield profits, their use has not been
widespread due to several barriers. First, people do not know where
to buy the newer technologies. Second, packages integrating various
technologies are not readily available. Consumers generally must buy
them piecemeal. Finally, there exists a payback gap. Individuals look
for paybacks that are quicker and larger than the long-term payback
that these technologies offer.
Traditional methods to encourage the implementation of these
technologies have included making loans and gifts and leasing
necessary equipment. Newer methods that hold promise include
holding auctions for energy, paying to save energy, selling efficiency,
establishing fees/rebates on new buildings and fuel-efficient cars, and
targeting and executing a massive retrofit campaign. These newer
methods would essentially create a new market for efficiency.
For more information on renewable technologies, write:
Rising Sun Enterprises
P.O. Box 586
Snowmass, CO 81654
or
Rocky Mountain Institute
1739 Snowmass Creek Road
Snowmass, CO 81654-9199
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Welcome and P2 Overview
Nancy Firestone
Special Counsel to the Deputy Administrator
We need creativity to solve the remaining environmental problems
that the Unfinished Business report describes: global warming, ozone
depletion, habitat destruction, and direct exposures (hazardous waste
sites, indoor air, pesticides). Pollution prevention (P2) will play a
major role in solving these problems.
To better understand this role and where P2 fits in the "big picture" of
EPA policy and operation, we should first discuss two other concepts
that the Administrator and the Deputy Administrator have promoted
in the Agency: strategic planning and total quality management.
Through strategic planning, we identify the most critical problems,
opportunities and new approaches to address these problems, and the
roles that EPA and States will play in solving the problems. Strategic
planning thus enables us to direct resources to sectors and to bypass
the media-specific categorizing that EPA has traditionally conducted.
The Administrator and the Deputy Administrator look to total quality
management (TQM) as a tool that helps to break down EPA's
organizational barriers. We must tackle these barriers if we are to
successfully undertake a sector-by-sector approach to critical
environmental problems.
For the P2 program, the strategic plan includes:
identifying specific contaminants on which to focus P2 efforts;
denning consistent measurable goals;
identifying how to achieve reductions in contaminant
use/emissions; and
addressing the contaminants through sector approaches (e.g.,
clustering rules, targeting research, conducting technology
transfer on available substitutes).
Through the Toxic Release Inventory (TRI), Regions will target
specific facilities that manufacture/use these contaminants and are
high-risk sources. States will serve as the front line for assuring the
implementation of P2 activities at these facilities.
We will achieve reductions through meetings with the senior
executives responsible for these facilities' operations and through
vigorous enforcement and permitting. Having defined measurable
goals, we will then be able to determine whether or not we have
achieved what we set out to do.
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EPA has all the tools necessary to undertake this aspect of the P2
strategic plan and to adopt a cross-media, sector approach.
The barriers that we do face involve Congress and EPA's organizational
structure. We are engaging in constructive dialogue with the Hill, but
it will take time to get Congressional support. As for the Agency's
internal structure, converting to a sector approach and reorganizing to
promote inter-program collaboration must come from within in order
to be most effective and acceptable to Congress.
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The Nature and Challenges of Pollution Prevention
Hank Schilling
Director, Office of Pollution Prevention
An official definition for P2 has not been developed. Without such a
definition, it may be helpful to think of P2 as the first two techniques
under the following hierarchy for dealing with waste:
1. use/source reduction
2. reuse/re cycling
3. treatment
4. disposal
Although use/source reduction and reuse/recycling are considered P2
techniques, reduction is preferable to recycling. In fact, including
recycling in the definition of P2 has been controversial.
P2 requires a broad, creative mindset. We at EPA should realize that
many industries have exhibited such a. mindset and have made great
strides in preventing pollution. We should foster closer relations with
these industries in order to keep them going in the right direction.
Within EPA, it is imperative that we take action now, while P2 is still
in the spotlight, to get everyone thinking about P2 and to make P2 a
part of EPA's way of doing business. We can do this by following
through on the 2% set-aside projects, evaluating our grant support,
and defining Headquarters and Regional roles for our next steps.
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Conference Expectations
PaulKeough
Deputy Regional Administrator, Region I
In order for P2 to be successful, every person and program in EPA
must think about and act to promote P2. In pursuit of this goal, we
have assembled to determine the P2 program's next steps. The
specific objectives of this conference are to lay the foundation for:
improving communications between Headquarters and Regions;
determining what roles each office/program should play;
establishing a common vision of short- and long-term goals;
sharing information on P2 activities throughout the Agency; and
* learning more about global P2 issues.
It is important that we focus on actions rather than academic issues
such as definitions. To this end, the major product of this conference
will be a list of action items for review by the Administrator and the
Deputy Administrator.
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Session
Regional Programs/Activities
Abby Swaine
Pollution Prevention Program, Region I
Region I's 2.2 FTE for P2 are supplemented by an inter-divisional task
force and by student interns. The core staff are in the Planning and
Management Division.
We have undertaken two major P2 efforts. First, we have established
the Northeast Pollution Prevention Council, a group of 15-20 leaders
in the public and private sectors. The council serves as a vehicle for
promoting cultural change and education. Its members give P2 high
visibility. Specific issues on which the council works include:
reduction of auto emissions, CFC substitutes, and government
transportation.
We have run into some problems in our support of the council. For
example, supporting the council is extremely time-consuming.
Members do not spend time outside of council meetings working on
issues. They also hold highly divergent 'views; thus it is difficult to
foster consensus.
Our second major effort is the development of our P2 strategy. The
task force disseminated and communicated our P2 goals to the rest of
the Region. We also developed a tracking/reporting system that
outlines the steps (with corresponding completion dates) needed to
achieve our objectives. Progress reports will be included in the
Deputy Regional Administrator's quarterly reviews. As the P2 program
matures, we wish to take a longer-term view in the strategy and
streamline its objectives.
Palma Rlsler
Office of Policy and Management, Region II
Region II does not have any official FTEs devoted to P2 work. We do
have an advisory group composed of deputy division directors, but no
staff workgroup exists.
Because we do not have any 2% set-aside projects. Region II's P2
program has an in-house credibility problem. Attempts to integrate
P2 into current activities have had mixed results, largely due to
inadequate communications.
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We are currently working on a number of initiatives, including
development of a waste reduction statement;
development of a a checklist for site visits;
targeting largest emitters with TRI; and
development of P2 guidance that includes industry-specific
techniques.
In order to expand the P2 efforts in Region II, we need to establish a
staff workgroup, conduct more extensive training, incorporate P2 into
strategic planning, and take steps to promote P2 in industrial
development activities.
Nancy Grundahl
Environmental Services Division, Region III
In FY90, Region III has 3.0 FTE dedicated to P2 work in addition to a
policy team and a staff workgroup. We have benefited from extensive
involvement by the Deputy Regional Administrator.
Internal efforts have focused on training inspectors, RCRA permit
writers, procurement of recycled goods, targeting with TRI data and
GIS, encouraging use of mass transit, and displaying P2 messages on
in-house video monitors. Other efforts include business, public, and
consumer outreach through EPA speakers.
In one of our success stories, using TRI data, we traced ground-water
contamination to IBM which agreed to phase out the sources of
contamination.
Betsy Shaver
Office of Policy and Management, Region IV
The Region IV P2 program enjoys strong support from the Regional
Administrator. Primary responsibility for the P2 program resides in
the Office of Policy and Management which coordinates all new P2
initiatives that have not been institutionalized into the program offices.
We have 1.0 FTE dedicated to P2 work.
Our outreach efforts have included enhancing the Waste Reduction
Resource Center to conduct more on-site work to assist State waste
reduction programs. We also train retired waste reduction assessors
to conduct waste reduction opportunity assessments.
"Inreach" efforts include:
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basic P2 training and orientation for all employees;
inspector training;
P2 incorporation into enforcement settlements;
new source review;
in-house recycling program; and
procurement of recycled goods.
Glass
Planning and Management Division, Region V
In Region V, we have a core staff of 0.7 FTE under the supervision of
the Planning and Management Division. In addition, we are forming a
P2 workgroup to oversee our five P2 grants and two 2% set-aside
grants.
Region V is historically enforcement-based; it is slowly accepting the
concept of P2. Some of our projects include developing a P2 strategy
for the Great Lakes, conducting P2 efforts in RCRA (training, permits,
use of TRI, advisory group for waste management), and assisting a
Milwaukee sewage district with its efforts to meet permit limits and
identify risks.
Lynda Carroll
Office of Planning and Analysis, Region VI
Region VTs P2 efforts began in March 1989 i We have 0.7 FTE of core
P2 staff, a steering committee of senior staff, and a staff workgroup.
The Office of Planning and Analysis coordinates all of their efforts.
We are pursuing a number of P2 activities, including:
* a joint venture with the University of Texas/Arlington (UTA) to
develop a network connecting UTA, EPA, businesses, industries.
State and Federal regulatory agencies, and other universities,
thereby facilitating research, technical assistance, and
dissemination of environmental knowledge;
an aggressive recycling effort for Federal offices;
working with the Mexican government to collect air quality
monitoring, meteorological, and emissions inventory data;
an evaluation of toxic pollutant releases from industrial plants;
outreach efforts to the media and the regulated industries; and
settlements with P2 provisions.
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In order to improve the Regional P2 program, we need to involve
representatives from all the program offices and to establish better
communication with our States.
Alan Wehmeyer
Waste Management Division, Region VII
Within Region VII, the Deputy Regional Administrator has lead
responsibility for P2 efforts, and I serve as the Regional P2
coordinator. A P2 advisory council of senior staff members provides
the vehicle for P2 communication throughout the Region. We do not
have any FTEs dedicated solely to P2 work; divisions simply give up
workyears.
The Region has a large number of P2 projects are underway. They
include efforts to:
develop educational materials suitable for kindergarten
through twelfth grade;
develop P2 technology with small quantity generator industry
groups;
reduce loading of agchemicals into two'surface water
impoundments;
implement procurement guidelines;
develop a corporate guide to pollution prevention with
Hallmark Cards;
conduct outreach with other Federal agencies to initiate office
recycling programs, develop waste reduction strategies, and
procure recycled paper and paper products; and
use TRI data to target prevention opportunities.
Don Patton
Policy and Planning Office, Region VIII
The Assistant Regional Administrator has lead responsibility for
Region VIII's P2 activities. A steering committee composed of deputy
division directors provides guidance for our efforts. Our core P2 staff
consists of 0.5 FTE.
Our ongoing P2 projects include:
establishing a non-profit environmental alliance with Martin
Marietta, Coors, Hewlett-Packard, and the Public Service
Company of Colorado to work on reducing solvents and
increasing water and energy conservation;
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funding 28 teachers to attend P2 presentations by all program
offices, consultants, and academics;
creating a used oil recycling center in conjunction with the
public-private partnership people; and
developing a cooperative Governmental/Private Multi-Media
Strategy of on-farm applied research and demonstration of
sustainable agricultural practices.
Laura Yoshii
Hazardous Waste Management Division, Region IX
A steering committee chaired by the Deputy Regional Administrator
and composed of office directors and their deputies provides policy
guidance for Region DCs P2 efforts. A core P2 staff (3.0 FTE in FY91)
carries out P2 activities under my supervision.
Accountability measures for our efforts do exist. The steering
committee receives status reports on P2 activities at their monthly
meetings. In addition, P2 activities are outlined in operating plans
and assessed in DRA quarterly reviews.
We are currently working on various projects to:
conduct hazardous waste minimization workshops for auto
repair shops, labs, etc. in conjunction with a county
government;
assist local governments in training inspectors to do waste
minimization assessments;
reduce metals loadings from POTWs through modification of
permits, workshops, videos, and development of waste
minimization programs;
incorporate P2 into enforcement settlements and waste
incineration permits;
publish P2 brochures for UIC Class V wells;
conduct educational outreach on TRI data;
publish a quarterly newsletter for Regional staff;
establish an in-house recycling program; and
enhance the collection of in-house P2 resources.
In the future, we intend to invest FTE more heavily outside of the core
P2 staff.
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David Teeter
Hazardous Waste Division, Region X
The P2 program in Region X consists of 1.5 FTE of core staff, a staff
workgroup, a steering committee comprised of division directors and
senior staff, and overall supervision from the Planning and
Management Division.
Region X's activities had been slowed by the lack of a Regional and
Deputy Regional Administrator.
Currently, our priorities are to:
build P2 into traditional programs;
establish a strong EPA/State relationship in P2 activities;
make greater use of data management tools; and
establish a means of measuring progress.
P2 projects underway include establishment of a Northwest P2
resource center, a recycling effort during the goodwill games,
establishment of an in-house recycling program, placement of
recycling bins in ferries, development of compliance/enforcement
tools to promote P2 in negotiations, and investigation of recycling in
Federal facilities.
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Session
Institutionalization/Integration
Institutionalization or integration refers to the process of making P2 a
part of every EPA employee's responsibilities and every program's
activities, and includes improving coordination between programs to
address multi-media issues. Since few additional resources are
available, in order to enhance the effectiveness of our existing
programs it is crucial that P2 become integrated into all of EPA's
existing program activities.
Effective institutionalization of pollution prevention in the Regions has
stemmed from senior management involvement in establishing
expectations and accountability. As a the result managers and staff are
willing to adopt pollution prevention, and make Regional
disinvestments which redirect resources to support pollution
prevention.
To date, many P2 activities have been initiated within Regional
program offices. These activities have resulted from Regional
initiatives brought about through the Regional P2 pilot projects as well
as through the set-aside projects and other cooperative efforts.
Common elements of achievements in institutionalizing P2 in the
Regions include: upper management (RA/DRA) involvement in
establishing expectations and accountability {i.e. through the quarterly
review process) and Regional disinvestments which redirect resources
to support pollution prevention.
Although HQ program offices are beginning to become involved in
some of the sectorial P2 initiatives, it is a common perception that
efforts to institutionalize P2 within the HQ program offices have
achieved limited success. Barriers to institutionalizing P2 include:
turf; inertia; lack of an established definition, clear expectations, and
accountability; and workload constraints.
The following recommendations are offered as suggestions to more
effectively promote institutionalization of P2 within EPA.
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ACTION PLAN
L Short-Term Actions
Education/Training
Require P2 training of all EPA employees.
Priority Setting
Immediately and clearly define P2 in a final P2 Policy Statement.
Establish a framework for identifying priority areas for P2
considering:
P2 experience and accomplishments to date;
Opportunity;
Risk;
Coverage (i.e. toxics, MSW, energy, agriculture); and
Cost
Establish a schedule and process for priority area identification.
Translation of Priorities into Action
Establish specific targets, goals, and expectations; include initial
targets, goals, and expectations in the P2 strategy; and make
the P2 strategy an Agency-wide strategy rather than an OPPE
strategy.
Establish means of accountability and reward for P2
approaches; involve Administrator or Deputy Administrator in
Advisory Committee process; and develop model language and
incorporate in performance standards to sponsor upper- and
mid-level management support of P2.
Include P2 explicitly in STARS targeting and reporting
requirements.
Assure that budgets and resources are initially flexible enough
to support P2 activities, and ultimately reallocate resources to
allow P2; include P2 in all NPM program elements and
workload models; and require an established level of
disinvestment and redirection of resources within program
offices to support institutionalization of P2.
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Build P2 more explicitly into strategic planning and
comparative risk activities; and involve P2 staff in strategic
planning preparations.
Assure that implicit P2 opportunities in new statutes and
programs are fully utilized (i.e. Clean Air Act Amendments
when passed, expanded FY 91 Subtitle D program).
Facilitate the integration of P2 enforcement and permitting by
clarifying Agency authorities in these areas and compiling
model and actual P2 enforcement (including settlements and
credits) and permitting provisions and requirements.
Long-Term Actions
Involve/reorient other Federal agencies (i.e. DOD, DOE, USD A,
DOI, Commerce, DOT, etc.) to better undertake P2 through:
cooperative efforts, and
Executive Orders/legislation.
Develop enforcement focus on enhancing compliance, in
addition to punishing non-compliance:
Encourage auditing;
Use inspectors;
Develop initiatives in high-risk industries; and
Match training and technical assistance with areas needing
special attention.
Assess regulatory and statutory mandates for P2; and
implement pilot projects pursuing multi-media P2 and
organizational integration.
Restructure the budget process to support P2.
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Speech
Coal Processes and Efficiency
Sandy Blackstone
Professor of Law
University of Denver
Political, legal, regulatory, and institutional issues have heavily
influenced coal processes and their effects on the environment, often
forcing industry to undertake inefficient processes and making it
impossible or infeasible for the coal industry to adopt approaches
designed to prevent, rather than control, pollution. This has been
evident in each phase of coal production and use, from coal mining
and transportation to generation and transmission of electricity.
In the area of coal production, certain regulatory and tax policies have
favored underground coal mining in the East -- a process that involves
more danger (in terms of human lives lost) and environmental
damages (subsidence and acid mine drainage) than surface mining,
primarily a western production process. In the 1970's, the
Congressional mandate for scrubbers in all new coal-fired power plants
served not only to eliminate the lower costs associated with producing
western coal, but also to incur enormous energy costs, reduce energy
efficiency, and increase CO2 emissions and solid waste disposal
problems.
Legal and institutional constraints have also prevented the coal
industry from using coal slurry pipelines, an efficient means of
transporting coal.
Of all the phases of coal production and use, the coal conversion phase
has the greatest potential for achieving increased energy efficiency.
Because of their improved efficiencies, "clean coal" technologies (e.g..
integrated coal gasification combined cycle system) can reduce acid
rain-type pollutants and CO2 emissions. Such technologies have been
demonstrated and can soon be used in commercial applications;
however, barriers to their use include conflicts among State public
utility commissions and lack of financial incentives for the capital
investments necessary.
We need to encourage the use of clean coal technologies. If we rush to
respond to concerns about acid rain and global warming, we force
industry to use existing technologies that have higher costs and that
result in greater pollution. Several aspects of the pending Clean Air
Act amendments appear favorable to clean coal technologies (e.g.,
emission allowances, emission trading), but schedules for
implementing these measures should allow for the integration of clean
technologies in new plants and the retrofitting of existing plants.
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Alternative means of reducing CO2 emissions globally are not as
feasible. CO2 scrubbing (removing CO2 from stack gases) is costly and
would require approximately 15% of power plant capacity. Using
natural gas or renewable technologies has limited global potential due
to economic and technical barriers.
Finally, the efficient transmission of electricity from surplus supplies
to areas with excess demand has been hampered by jurisdictional
conflicts among Federal, State, and local agencies.
Thus, the major obstacles to employing pollution prevention in the
coal industry are not technical and economic, but political and
institutional.
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Session
Headquarters Initiatives
Hank Schilling - Legislation
Director, Office of Pollution Prevention
Reauthorization of the Clean Air Act has taken precedence over P2
legislation; it is unlikely that such legislation will be proposed this
year.
The P2 policy statement is in the draft stage. Anyone interested in
obtaining a copy of the draft should see me.
The next five speakers will inform you or activities in various program
offices. The last three speakers from the Office of Pollution
Prevention will fill you in on some of our activities.
Richard Hefter
Office of Pesticides and Toxic Substances
The Office of Pesticide Programs (OPP) has two P2 goals: (1)
restrict/eliminate pesticides causing adverse effects; and (2)
encourage the development of safer pesticides. OPP will pursue these
goals through pesticide registration, pesticide reregistration, review of
volatile organic and other chemicals in pesticide formulations,
implementation of the ground-water/pesticide strategy, and
development of worker protection regulations and economic
incentives.
Susan Hazen
Office of Toxic Substances
The Office of Toxic Substances (OTS) seeks to build P2 into its TSCA
responsibilities which focus on risk mitigation and have traditionally
relied on command and control. OTS's P2 initiatives include:
a 2% set-aside project to reduce lead exposure;
support for a P2 university research center;
incorporation of a P2 review of TSCA chemicals before they go
on the market;
substitutes for TRI chemicals;
expansion of SIC codes covered by TRI reporting;
inclusion of Federal facilities in TRI reporting;
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mandatory P2 questions in TRI; and
revision of the Section 313 chemical list.
Gregory Ondich
Office of Research and Development
The Office of Research and Development (ORD) published the
Pollution Prevention Research Plan (Report to Congress) in March
1990. The plan targets hazardous wastes, municipal solid wastes.
pesticides, stratospheric ozone depletion/global climate warming,
indoor air pollution, and consumer products. Within these areas, ORD
places greater emphasis on product research, socioeconomic and
institutional research, and technology transfer efforts.
ORD also provides support for the Pollution Prevention Information
Clearinghouse (PPIC) and the American Institute for Pollution
Prevention (AIPP), an advocacy group composed of officials from
industry, academia, professional societies, and government.
Vivian Daub, Deborah Gillette
Office of Water
P2 efforts are not new to the Office of Water (OW). OW has already
established non-point source, wellhead protection, and effluent
guidelines programs that focus on P2. Newer P2 initiatives within OW
include:
reviewing P2 legislation;
developing strategic plans;
taking the lead on agricultural sector workgroup;
promoting P2 in effluent guidelines;
developing NPDES permit writer training courses that
incorporate P2 concepts; and
examining the reuse of sludge.
Cheryl Wasserman
Office of Enforcement
Enforcement is an important component to the prevention of
pollution. Liability, public disclosure, and the threat of penalty forces
the regulated community's attention to P2.
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The Office of Enforcement's (OE's) P2 strategy involves enhancing
ongoing outreach in environmental auditing and environmental
management; developing policy on the incorporation of P2 in
settlement conditions; targeting based on risk and P2 opportunities;
using compliance inspectors to disseminate information; using the
National Environmental Policy Act and the Federal Agency Roundtable
to promote P2; promoting P2 on Indian lands; and promoting P2 in
the annual budget process.
OE has already developed an interim policy on enforcement
settlements and a system for evaluating such settlements. Peter
Rosenberg has responsibility for the development of this policy.
Please send him case examples in which you have incorporated P2
into enforcement settlements.
John Cross - Authorities, 2% Projects, Resources
Office of Pollution Prevention
The Office of Pollution Prevention (PPO) is examining existing statutes
to determine which ones accommodate P2 efforts. A general
statement citing these authorities will be incorporated into the P2
strategy.
Approximately 60 to 75 percent of the 2% set-aside projects are
progressing. The remaining projects await clearer definition. PPO has
sought clarification from the Office of the Comptroller on the logistics
of getting the resources for the 2% projects to the program offices. In
FY91, the budget for 2% set-aside projects may be cut; however, it is
uncertain as to how large the cut would be.
The overall FY91 budget allocates approximately $1.1 million for
Regional activities ($30,000 per Region). An additional $3.0 million
will be available for grants. No Congressional add-on is expected.
Deborah Hanlon - Training
Office of Pollution Prevention
Training is critical in order to integrate P2 into the EPA "corporate"
culture. PPO has formed a training subcommittee of the EPA Pollution
Prevention Advisory Committee. The training subcommittee will assist
in implementing EPA's P2 training strategy, identifying training needs
and resources, establishing criteria for P2 programs, developing
training tools for use by Agency, State, and industrial personnel, and
communicating existing P2 training opportunities to other EPA offices
and Regions.
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The training strategy that PPO and the training subcommittee have
developed and will implement consists of four phases: (1) "generic"
P2 training workshop for EPA, State, and local government personnel;
(2) PPIC and PIES hands-on training; (3) industrial pollution
prevention workshops; and (4) permits, enforcement, and other
industry-specific workshops.
Jerry Kotas - PPO Overview
Office of Pollution Prevention
We are making progress in promoting P2 throughout the Agency. As
we work to further support P2 efforts, we need to focus on effecting
transformational change change from within.
The Pollution Prevention Division's numerous activities are carried out
by 19 people who field approximately 300 calls per day. As such, we
are spread thin and need to determine how to target our efforts most
effectively while continuing our service orientation. In addition, we
need to balance our long-term and short-term efforts.
Besides those projects that you have heard about from other speakers,.
the division has responsibility for a large number of other projects,
including:
targeting rules and clusters of rules for P2 efforts;
targeting specific chemicals for P2 efforts;
developing the P2 strategy;
assisting other programs with their strategic plans;
establishing Headquarters desk officers;
leveraging outside groups (e.g., SAB, AIChE);
developing and distributing a P2 newsletter; and
supporting international efforts with OECD, UNEP.
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Speech
Renewable Energy Technologies for Electricity
Robert Stokes
Deputy Director for Research
Solar Energy Research Institute
Natural, renewable energy resources -- sunlight, wind, trees, plants,
rivers, and hot springs provide approximately nine percent of our
domestic energy, supplying electricity, heat, gaseous fuels, and liquid
transportation fuels for homes, cars, and industries.
Renewable energy technologies for electricity include:
Hydropower
Biomass combustion of wood, agricultural wastes, municipal
solid wastes, and gases generated by landfills
Geothermal Energy
Wind Machines
Solar Thermal Power Plants
Photovoltaics -- conversion of sunlight directly to electricity
using solid-state technology
Electricity from renewable energy systems is cost-competitive,
ranging from five to ten cents per kilowatt-hour. The costs associated
with most of the technologies listed above will decrease in the future
as the technologies mature. In addition, the modular nature of
renewable energy systems allow utilities to add capacity in step with
demand, without long lead times or major capital investments. Thus,
using renewable energy makes good economic sense.
It makes good environmental sense as well. Using renewable energy
rather than fossil fuels can help utilities to reduce their carbon dioxide
emissions.
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Speech
Global Warming
Richard Anthes
President
University Corporation for Atmospheric Research
The year 1988 was the warmest year on record in the Northern
Hemisphere. Severe droughts plagued much of the world, while
floods devastated other regions. Hurricane Gilbert, the strongest
Atlantic hurricane on record, caused massive property damage in El
Salvador. In its January 1989 issue, TIME Magazine named the
endangered Earth "Planet of the Year".
The events of 1988 do not prove that the Earth is warming up due to
an enhanced greenhouse effect associated with a rapid increase in
"greenhouse" gases such as carbon dioxide, methane, and
chlorofluorocarbons, but they are consistent with changing weather
and climate patterns that many scientists believe is possible, or even
likely, in the decades ahead. Many scientists believe, in fact, that the
earth is headed for a climate warmer than ever before experienced by
human civilization.
My talk reviews what is currently known about the changing
atmosphere and what is currently known about the likely climate
changes in the future. We know without a doubt that radioatively
active greenhouse gases are increasing; for example, the carbon
dioxide in the atmosphere has increased by nearly 15% in the last 30
years and at a 1990 concentration of 353 ppmv is now higher than at
any time in the last 160,000 years. Climate models indicate that this
increase, plus the increase in other greenhouse gases, is likely to
cause an increase in global mean surface temperature by between 1.5
°C and 4 °C in the next 50 years.
The increase in greenhouse gases is being caused by an
unprecedented growth in human population. The doubling time for
the world population has decreased from 1,500 years in 8000 B.C. to
less than 35 years at present. The exponential growth in human
population and the activities of this population are the fundamental
causes of the increasing greenhouse gases. They are also responsible
for other assaults on the environment such as the deforestation of
tropical regions and the decrease in the Earth's protective ozone layer.
Thus the solution to global atmospheric pollution and environmental
destruction must include a stabilization of the world's population.
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Session
Communications among Headquarters and Regions
Effective communications among all parties in the pollution
prevention program are critical to its success. Only after internal P2
program communications are effectively established can the program
coordinate its efforts successfully with other Agency programs and
with organizations external to EPA.
The Headquarters P2 program has the responsibility to focus its
communications in order to provide leadership, direction, and
financial, legal, technical, administrative, and policy support. The
core P2 personnel in the Regions must be informed of Headquarters
and other Regional activities in order to credibly and effectively
promote and carry out the program and to take advantage of other
efforts so as not to "reinvent the wheel".
Communications should serve the following purposes:
Promote the development of a consistent, yet creative and
innovative program by the Regions and Headquarters;
Eliminate/reduce duplication of efforts;
Reduce conflict and omission;
Provide.cross-fertilization of ideas;
Support effective resource allocation and use; and
Provide information, guidance, and cooperation.
The following action plan, developed by conference participants,
identifies specific items that will assist in improving communications
among Headquarters and Regions to serve these purposes.
Responsibility for the items are indicated in parentheses ( ).
ACTION PLAN
L Short-Term Actions
Telephone Calls
Give Regional contact calls higher priority (HQ)
Provide more information in messages left for a HQ response
(Regions)
Obtain necessary telecommunications tools/services (i.e.,
proper cabling, phone service, E-mail) (HQ)
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Conference Calls
Schedule conference calls on a regular basis (HQ)
Focus calls on a topical subject (HQ/Lead Region)
Provide information to be discussed prior to conference call
(HQ)
Review and Comment of Documents
Include Regions in review of all policy-related documents
(HQ/Lead Region)
Focus Regional review through lead Region (HQ/Lead Region)
Allow adequate time for review; inform Regions of upcoming
review schedules so as to effect better planning (HQ)
Reports
Send Regions draft bi-weekly reports (HQ)
Send HQ quarterly management memos and/or more frequent
reports that are currently prepared by Regions (Regions)
Send weekly "care packages" to Regions (HQ)
Newsletter
Retain; it is a good mechanism
EL Medium- to Long-Term Actions (May Require Study or
Changed Procedures)
Telephone Calls
Funnel calls (from Regions) to the Regional contact(s) more
effectively; requires determining who and how many Regional
contacts there are (HQ/Regions)
Establish Directory for P2, including organization, telephone,
and electronic mail numbers and functional/activity lead
responsibility of all P2 staff in HQ OPPE, ORD, the programs, and
likewise in the Regions/labs (HQ/Lead Region)
Investigate the use, but not abuse, of voice mail to ease the
telephone answering crunch (HQ/Regions)
Conference Calls
Involve Regions more and in a more timely way in agenda
formulation (HQ/Lead Region)
Clearinghouse
Include more Regional materials:
Define what these materials are;
Determine a mechanism to write the materials up; and
Determine how to include them in the Clearinghouse
(Regions/Clearinghouse/HQ)
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Use the Clearinghouse more fully
Determine how to do this (All/Clearinghouse)
Include more HQ materials (HQ/Clearinghouse)
Lead Region
Enhance the role of the Lead Region in coordinating
communication between Regions and HQ on: policy/regulations,
operating procedures and processes, budget, resource allocation
roles, etc. (Lead Region/Regions/HQ)
Review and Comment
Define role of Regions in shaping policy (HQ/Lead Region)
Meetings
Arrange more frequent meetings (HQ/Lead Region)
Focus meetings for smaller groups and single topics (HQ/Lead
Region)
Reports
Write and submit reports on projects when they start and end
in a case study or profile format (HQ/Regions)
Newsletter
Include more Regional information (HQ/Regions)
E-Mail
Look into more use of E-Mail (HQ/Regions)
DRAs
Determine what information they need (Regions)
Send them P2 information in brief form with high HQ signature
(HQ)
HQ Desk Officers
Define and enhance desk officer system to provide better
service to the Regions (HQ)
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Session
Program Leveraging and Interfacing
The pollution prevention program has intensified its efforts to educate
other EPA programs and Federal agencies about pollution prevention,
and to pursue joint pollution prevention initiatives with these
programs and agencies. Within EPA, the pollution prevention
program has begun to work with Public/Private Partnerships,
Technology Transfer. Strategic Planning, Comparative Risk, and
Enforcement Credits to infuse these programs with the pollution
prevention ethic. Outside EPA, the pollution prevention program has
begun to develop policies and projects with the Departments of
Defense, Energy and Agriculture.
Finally, the pollution prevention program is communicating with
national associations and groups whose efforts can further the goals of
the pollution prevention program.
However, the pollution prevention program's efforts to work with
other EPA programs. Federal agencies and other groups are currently
hampered by a perceived lack of "clout" behind pollution prevention
within EPA.
For the pollution prevention program to be able to market its concept
effectively and leverage outside resources, it must be able to
demonstrate that it has a coherent identity, institutional recognition
and resources. The pollution prevention policy statement and agency-
wide strategy will make great strides in establishing a creditable
identity. However, most specific policies (permit writing,
enforcement credit projects, inspections, etc.) are still far from
completion.
Upper management buy-in and earmarked resources for pollution
prevention within other programs would increase institutional
recognition. Increased resources would enable the pollution
prevention program to more aggressively pursue agreements with
other EPA programs, Federal agencies and outside groups.
Given the limited resources available currently, the pollution
prevention program is concentrating its efforts on the following:
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ACTION PLAN
Short-Term Actions
Use fully environmental audit capabilities and mechanisms,
including manuals, protocols, and training workshops that have
been developed by HQ.
Keep Regions abreast of DOD, DOE, and other Federal activities
so as to facilitate Regional participation in inter-Agency
initiatives.
n. Long-Term Actions
Within EPA, focus on leveraging strategic planning, technology
transfer, comparative risk, and public-private partnership
efforts efforts that are most receptive to and supportive of
P2 and that have high potential for "symbiotic" relationships.
Work with the new Office of Environmental Education to
promote P2.
Target leveraging efforts outside EPA to those Federal agencies
(DOD, DOE, DOI, USDA) and groups that have significant P2
opportunities.
Leverage training with industry, universities, and businesses.
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Session
State Programs (including Tribal)
Currently, a number of States have dynamic or evolving programs that
can point to significant pollution prevention achievements. In fact.
many States are at the forefront of pollution prevention
implementation. Other State programs, however, are only beginning
and are not yet fully operational. Many States have no recognizable
pollution prevention program or are hampered by the media-specific
nature of their environmental organizations. State pollution
prevention prevention programs also vary as to their focus (single or
cross-media) and their level of funding. The Pollution Prevention
Division in Headquarters has awarded 53 grants to 37 States. Most of
these grants have been awarded to State regulatory and environmental
health agencies. In FY 91. approximately $5.0 million will be available
to States, Tribes, and inner-state agencies.
For EPA, there exist two important questions concerning state
pollution prevention programs. First, what can EPA do, besides award
grants, to promote and support State and Tribal pollution prevention
programs? Second, how should grants programs be designed and
implemented to best promote State and Tribal pollution prevention
programs? The following action plan identifies specific items that can
help to answer these questions.
ACTION PLAN
L Short-Term Actions
Promote/Develop State and Tribal Programs
Identify and focus on areas where States can be helped most:
Program implementation activities;
Technical assistance; and
Grant application preparation.
Identify and take advantage of other tools which can help to
improve State programs:
State/EPA Agreement preparation meetings and reviews
Other Grants: RCRA, Superfund;
State Minimization Roundtable;
Clearly stated expectations in a policy/strategy statement; and
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Training.
Create incentives/credits for State implementation of P2.
Grants Management
Create a HQ/Region workgroup that will work to improve,
clarify, and communicate the process for (1) determining
program objectives/ direction/criteria which specifically
support P2; (2) determining HQ/Region roles; (3) targeting and
awarding State grants and (4) expediting the transition of the
grant program (i.e., allocation of resources, administration, and
management) to the Regions.
Inform Headquarters if interested in taking over grants
management (Regions).
(Grants management includes receiving/reviewing semi-annual
reports, providing technical assistance, conducting on-site
visits, and conducting informal communications.)
n. Long-Term Actions
Develop response to the Appropriation Committee's proposal to
change P2 grants into a 50-50 matching grant program.
Transfer management of the program to ROs, with policy and
guidance from HQ (traditional EPA roles).
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Session
Conference Wrap-up
PaulKeough
Deputy Regional Administrator, Region I
We have discussed institutionalization/integration, communication,
leveraging/interfacing, and State programs, and we have appointed
groups to analyze each of these issues and recommend how to
overcome some of the barriers identified during the conference.
I think it is important for senior Agency management to know what
progress the P2 program has made. To this end, Region I, as lead
Region, will be responsible for getting together a package to be
presented to the Administrator, the Deputy Administrator, the Deputy
Assistant Administrator for OPPE, and all the Regional and Deputy
Regional Administrators. This package will contain a brief overview of
the conference, summaries and action plans for each of the four
sessions, and a one to two page summary from each Region and from
each Headquarters program on major success stories.
In addition, we will invite the Administrator to the next Pollution
Prevention Advisory Committee meeting. Hank and I will give him a
brief summary of what has happened and is happening in the P2
program. We would like to bring in some of the Regional P2 people to
brief the Administrator on several of their promising projects.
It is extremely important to keep up the momentum, especially given
the uncertain budget situation. We need to show that for a small
investment, P2 achieves significant accomplishments.
Because what we do as follow-up determines how truly successful this
conference is, I propose that in the next six months a smaller group
convene and assess how far the P2 program has progressed. The six
month timeframe is crucial; I do not think it is wise to wait a whole
year before assessing our progress. This smaller group can then use
their assessments to develop an agenda for the next national meeting.
Laura Yoshii
Deputy Director, Waste Management Division, Region IX
Upon reflection, one of the most outstanding features of this
conference and the P2 program is the quality of the people. This is a
bright, committed, energetic, action-oriented group. Attending this
conference has revitalized me and my thinking about the changes
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needed in the Agency. Seeing so many talented people has made me
confident that such changes will happen.
Paul's plan for "advertising" the P2 program is a good one; it will help
us gain recognition for the important activities that we have
undertaken.
From Nancy Firestone's presentation and several of the sessions, it
became clear to me that there are several areas that we need to focus
on. First, we need to tie together strategic plans and comparative risk
studies so that we can better coordinate all of our activities. Second,
we need to learn more about total quality management and how it will
help us change our way of doing business for the better. Third, we
need to take fuller advantage of the clearinghouse. Finally, we need to
work on leveraging other Agency programs and breaking down the
organizational barriers.
Jerry Kotas
Director, Pollution Prevention Division
I would like to stress the importance of keeping senior Agency
management informed of our progress. Paul has emphasized this, and
I agree with his plan.
As Nancy Firestone and others pointed out, it is necessary to balance
specific short-term targets that can achieve tangible successes with
medium- and long-term goals (e.g., moving towards a sector focus). It
will be a difficult balancing act in which leveraging will be the key to
success. Of course, we do need senior management support to
leverage successfully.
I recommend that each Region and each office in Headquarters
establish a negawatt expert familiar with the types of technologies that
Amory Lovins presented.
What the P2 program is doing is not easy; we are trying to change the
Agency's traditional way of doing business. To accomplish this, we
have to keep working together.
Hank Schilling
Director, Office of Pollution Prevention
In the past three days, we have voiced differing views, but have
managed to keep the conference positive and productive. Thus, I am
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filled with ideas and insights. A follow-up document describing what
we have done will help to turn all of our ideas into concrete actions.
If you wish to see the current draft policy statement, let me know. I
am especially interested in hearing about any conceptual errors you
may find.
Thanks to everyone.
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Executive Action Flan
As lead Deputy Regional Administrator for the Office of Policy,
Planning and Evaluation, Paul Keough chaired the P2 Conference and
compiled the following Executive Action Plan which was presented to
the Administrator. These action items along with the individual
session plans constitute the overall Action Plan from the conference.
I. POLICY ACTION ITEMS
The Proposed Pollution Prevention Policy Statement has not yet been
finalized, leading to confusion in EPA, industry. States and the public
as to what constitutes pollution prevention.
ACTION OPPE should release a final pollution prevention
policy statement which clearly and concisely defines
pollution prevention by October 1, 1990.
Pollution prevention can have a beneficial impact in all sectors of
society. It is important to maintain efforts in various sectors so that
pollution prevention does not become associated only with toxics, or
only with particular chemicals. The planned pollution prevention
strategy should develop a framework the ability to build on pollution
prevention experience and accomplishments, existing program
opportunities, risk, cost, and technical feasibility.
ACTION Charge the Pollution Prevention Advisory Committee
with identifying a broad range of pollution
prevention target areas by November 1990.
The proposed pollution prevention policy statement broadly defines
source reduction and recycling as pollution prevention. Lack of
explicitly defined actions and expectations of Federal. State and local
programs has hampered progress in these areas.
ACTION The Pollution Prevention Advisory Committee should
develop specific targets, goals, and expectations, and
communicate them nationally through the Strategy,
and through all of our programs.
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Few programs and statutes (i.e. Clean Air Act Amendments, FY '91
RCRA Subtitle D Program, strategic planning, comparative risk. Total
Quality Management) offer a unique opportunity to design pollution
prevention right into regulations and operating procedures rather
than later conducting a "retrofit".
ACTION The advisory Committee, working with appropriate
senior managers should insure that implementation
efforts for new programs should incorporate
pollution prevention activities.
H. MANAGEMENT SYSTEM ACTION ITEMS
Few managers have used their flexibility to commit resources to
support pollution prevention activities within their programs, and it is
unclear what workload model tradeoffs may realistically occur. Most of
the Regions have achieved initial success through unofficial, marginal
disinvestments within their programs and redirecting FTE to support
pollution prevention.
ACTION HQ program offices should receive clear direction
from the Administrator to redirect some portion
of workload model FTEs to support Regional
pollution prevention activities in their program area.
The level of FTE support should be consistent with
the level of pollution prevention activities identified
in the National Program's strategic plan. Regions should
be accountable for these FTEs through
existing accountability systems.
While the integration of pollution prevention into environmental
programs is a major EPA goal, the level of resources dedicated to this
effort is inadequate to produce timely results.
ACTION Beginning in FY '91, the P, E & A workload model
should provide a minimum of 4 FTEs per region to
support "core" pollution prevention activities and
pollution prevention demonstration projects in EPA
and in States.
Most state-based environmental management activity occurs through
mechanisms of various media-specific grant programs. Currently
these grant mechanisms do not recognize or include pollution
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prevention principles and/or related guidance in implementing
prevention.
ACTION EPA should include specific pollution prevention
language and guidance in all grant-related negotiations
and other activities with the States. An agencywide
workgroup, including representatives from EPA Regions
and HQ program offices (including GAD policy office staff.)
should be established to set priorities and develop
mechanisms necessary to begin to incorporate pollution
prevention principles into media-specific grant programs.
ffl. SUPPORT AND TRAINING ACTION ITEMS
In order to gain widespread exposure and support among public and
private environmental officials, pollution prevention success stories
must be developed and circulated.
ACTION The Pollution Prevention Newsletter has
achieved considerable success in telling the pollution
prevention story to a wide audience. The Pollution
Prevention Division should build on this success and
expand the content and readership of the newsletter.
The newsletter should contain a section dedicated to
regional programs, events and success stories.
Reorienting the Agency toward pollution prevention will require an
understanding of pollution prevention opportunities and "buy-in" by
employees. Proper training is essential to achieving this reorientation.
ACTION The EPA Training Institute, in association with
Headquarters and Regional offices, should develop
pollution prevention training curriculums which provide
introductory pollution prevention orientation courses, and
modules which can be incorporated into existing, program
specific training courses.
As pollution prevention becomes part of EPA's culture, it must be part
of existing accountability and rewards structures. These elements
have been critical to the success of the Regional pollution prevention
programs.
ACTION OHRM should develop model pollution prevention
language for inclusion in the performance standards of
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senior managers by 1991 mid-year reviews. OPPE should
include existing pollution prevention programs in STARS
targeting and reporting requirements for FY 92.
Pollution prevention programs require visible upper management
support.
ACTION The Administrator or Deputy Administrator
should participate in the Advisory Committee process.
Promoting pollution prevention through enforcement and permitting
authorities is hindered by lack of understanding, disagreements about
available authority, and lack of model language and conditions.
ACTION A task force, including Office of General Council, the
Pollution Prevention Division, National Program staff and
Regions should determine the full extent of EPA's
authority for pollution prevention in permitting and
enforcement by April 1991. The task force should work
with the Advisory Committee to insure that pollution
prevention language and conditions are available
throughout the Agency.
Based on feedback from many States, the Agency has not been clear
enough in the messages we are sending to the States in terms of why
and how pollution prevention should be institutionalized into
environmental management priorities.
ACTION The Advisory Committee, working through National
Program Managers and Regions should improve current,
and establish additional, tools to assist States in
strengthening their pollution prevention programs. Such
tools may include: a policy statement with clear
definitions; a strategy document with clearly defined roles
and responsibilities for EPA HQ and Regions and the
States; the National Roundtable on State Waste Reduction
Programs; training programs; and other media-specific
grant programs.
IV. LONG TERM ACTIONS
Pollution prevention can produce important environmental results in
areas beyond the realm of traditional EPA programs, including energy,
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transportation and agriculture. Other federal agencies/departments
have authority and policy responsibility that can affect pollution
prevention in these areas.
ACTION EPA must work with these other federal
agencies/departments (i.e. DOD, DOE, DOI, DOT.
Commerce) and the Administration to reorient them to
better understand the benefits of implementing pollution
prevention in their areas of responsibility. The
cooperative efforts should extend beyond HQ to involve
Regional Offices as well.
Successful enforcement programs are an influential factor in
motivating the regulated community to undertake pollution
prevention. However, preventive solutions to violations often take
longer to implement than command and control approaches, allowing
longer periods of non-compliance. This time lag leads to conflict
between aggressive enforcement and pollution prevention.
ACTION A committee composed of OE, PPD, and program
representatives should develop a policy that strikes a
balances between the mandates of enforcement and
prevention programs.
Pollution prevention approaches are often inconsistent with the
statutory and regulatory responsibilities of national programs and their
regional counterparts.
ACTION Each program should work with General Council and the
Pollution Prevention Division to review their authorities
and responsibilities to ensure that all pollution prevention
opportunities are identified. Unnecessary barriers to
pollution prevention within existing regulations should be
identified, and action taken to remove them. A report for
each program should be prepared by the beginning of
FY92.
The Agency's organizational structure, based on separate
environmental laws, has produced a compartmentalized approach to
environmental protection with resulting cross-media impacts. This is
a significant barrier to multimedia pollution prevention efforts.
ACTION The Advisory Committee should authorize and support
cross-media demonstration projects to explore ways of
integrating pollution prevention into our existing
organizational structure.
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Appendices
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U.S. Environmental Protection Agency
National Pollution Prevention Conference
July 30 - August 2, 1990
ATTENDEES
Algazi, Danielle
Protection Specialist
U.S. EPA, Region 3
841 Chestnut St.
Philadelphia, PA 19107
(215) 597-1168
Allman, Kristy
PET Engineer
SAIC
8400 Westpark Drive
McLean, VA 22102
(703) 734-4388
Atcheson, John
Pollution Prevention Division
U.S. EPA, HQ
401 M Street, SW
Washington, DC 20460
(202) 340-3126
Bouchard, Dermont
Research Chemist
U.S. EPA, Region 7
726 Minnesota Ave.
Kansas City, KS 66101
(913) 551-7519
Cameron, Elizabeth
Pollution Prevention
U.S. EPA, Region 9
75 Hawthorne St.
San Francisco, CA 94105
(415) 744-2190/FTS 484-2190
Childs, Sharon
Program Analyst
U.S. EPA, Region 8
999 18th Street, Suite 500
Denver. CO 80202
(303) 293-1471/FTS 330-1471
Allen, Catherine
Environmental Engineer
U.S. EPA, Region 5
230 S. Dearborn Street
Chicago, IL 60604
(312) 886-0136
Anderson, Kathleen
Program Analyst
U.S. EPA, Region 8
999 18th Street, Suite 500
Denver. CO 80202
(303) 293-1454/FTS 330-1454
Black. Bill
Water Management Division
U.S. EPA, Region 6
1445 Rose Ave.
Dallas, TX 75202
(214) 655-7130/FTS 255-7130
Brodtman, Walter
Office of Research & Development
U.S. EPA, HQ
401 M Street, SW
Washington, DC 20460
(202) 382-2615
Carroll, Lynda
Office of Planning & Analysis
U.S. EPA, Region 6
1445 Rose Avenue
Dallas, TX 75202
(214) 655-6525/FTS 255-6525
Daub, Vivian
Env Protection Specialist
Office of Water
U.S. EPA, HQ
401 M Street, SW
Washington, DC 20460
(202) 475-6790
Appendix A
1
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Davenport, Thomas
Regional NFS Coordinator
U.S. EPA, Region 5
230 S. Dearborn Street
Chicago, IL 60404
(312) 866-0209
Dick, Kevin
Pollution Prevention
U.S. EPA, Region 9
1235 Mission Street
San Francisco, CA 94044
(415) 744-2189/FTS 484-2189
Edwards, James R
Pollution Prevention Division
U.S. EPA, HQ
401 M Street, SW
Washington, DC 20460
(202) 382-6920
Esher, Diana
Env Planning & Assessment Sec.
U.S. EPA, Region 3
841 Chestnut Street
Philadelphia, PA 19107
(215) 597-1196
Flora, David
RCRA State Program Sec.
U.S. EPA, Region 7
726 Minnesota Avenue
Kansas City, KS 66101
(913) 551-7523
Frizzell, Damon
ARTX/TOPE/PPOS
U.S. EPA, Region 7
726 Minnesota Avenue
Kansas City, KS 66101
(913) 551-7560
Gillette, Deborah
Enforcement and Permits (OWEP)
U.S. EPA, HQ
401 M Street, SW
Washington, DC 20460
(202) 382-2656
Dholakia, Umesh
Air Compliance Branch
U.S. EPA, Region 2
26 Federal Place, Room 500
New York, NY 10278
(212) 264-6676
Dunaway, Georgia
Risk Reduction Engineering, ORD
U.S. EPA
26 W. Martin Luther King Drive
Cincinnati, OH 45268
(513) 569-7650/FTS 684-7650
Elliott, Claire
Environmental Engineer
U.S. EPA, Region 9
75 Hawthorne St.
San Francisco, CA 94105
(415) 744-1908/FTS 484-1908
Fenemore, Robert
Office of Groundwater Protection
U.S. EPA, Region 7
726 Minnesota Avenue
Kansas City. KS 66101
(913) 551-7033/FTS 276-7033
Foecke, Terry
State National Roundtable
1313 5th Street, SE
Minneapolis, MN 55414
(612) 379-5995
Gangmark, Carolyn
Pollution Prevention Contact
U.S. EPA, Region 10
1200 6th Avenue
Seattle, WA 98101
(206) 399-4072
Glass, Linda
Pollution Prevention Coordinator
U.S. EPA, Region 5
230 S. Dearborn Street
Chicago, IL 60604
(312) 886-1019
Appendix A
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Grundahl, Nancy
Environmental Planning Sec.
U.S. EPA, Region 3
841 Chestnut Building
Philadelphia, PA 19107
(215) 597-0355
Hazen, Susan B.
Pesticides & Toxic Substances
U.S. EPA, HQ
401 M Street, SW
Washington, DC 20460
(202) 382-3667
Hemby, James
Pollution Prevention Program
U.S. EPA, Region 3
841 Chestnut Building
Philadelphia, PA 19130
(215) 597-8327
Keough, Paul
Deputy RA
U.S. EPA, Region 1
JFK Federal Building, Rm. 2203
(617) 565-3402/FTS 835-3402
Kircos, Suzanne
Public Affairs Specialist
U.S. EPA, Region 5
230 S. Dearborn Street
Chicago, IL 60614
(312) 353-3209
Kotas, Jerry
Pollution Prevention Division
U.S. EPA, HQ
401 M Street, SW
Washington, DC 20460
(202) 245-3557
Krishnan, Bala
ORD/OEETD
U.S. EPA, HQ
401 M Street, SW
Washington, DC 20460
(202) 382-2583
Hanlon, Deborah
Pollution Prevention Division
U.S. EPA HQ
401 M Street. SW
Washington, DC 20460
(202) 245-4164
Hefter, Richard
Pesticides & Toxic Substances
U.S. EPA. HQ
401 M Street, SW
Washington, DC 20460
(202) 382-2892
Holtzclaw, Brian
Environmental Engineer
U.S. EPA, Region 4
345 Courtland St., SE
Atlanta. GA 30365
(404) 347-7108/FTS 257-7108
Kern, Thomas
American Management Systems
1777 N. Kent Street
Arlington, VA 22209
(703) 841-5751
Koines, Arthur
Office of Pollution Prevention
U.S. EPA, HQ
401 M Street. SW
Washington, DC 20460
(202) 382-4030
Krieger, Jackie
Pollution Prevention Division
U.S. EPA, HQ
401 M Street, SW
Washington, DC 20460
(202) 245-4172
Kulstad, Susan
Planning & Analysis Section
U.S. EPA, Region 1
JFK Federal Building
Boston. MA 02203
(617) 565-3378/FTS 835-3378
Appendix A
3
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LaPosta, Dore
Hydrologist
U.S. EPA, Region 2
26 Federal Plaza
New York, NY 10278
(212) 264-4124
Mahoney, Mark
Pollution Prevention Manager
U.S. EPA, Region 1
JFK Federal Building
Boston, MA 02203
(617) 565-3387/FTS 835-3387
Michaels, Rowena
Office of Public Affairs
U.S. EPA, Region 7
726 Minnesota Ave.
Kansas City, KS 66101
(913) 551-7003
Myles, Morse
ORD
U.S. EPA, HQ
401 M Street, SW
Washington, DC 20460
(202) 475-7161
Ondarza, Arnold
Hazardous Waste Mgmt Div
U.S. EPA, Region 6
1445 Ross Avenue
Dallas, TX 75202
(214) 655-6770
Palmer, Kevin
Chemist
SAIC
8400 Westpark Drive
McLean, VA 22102
(703) 821-4600
Pepino, Richard V.
Environmental Assessment Br.
U.S. EPA, Region 3
841 Chestnut Building
Philadelphia, PA 19107
(215) 597-1182
Lewis, Nancy
Planning & Analysis Section
U.S. EPA, Region 1
JFK Federal Building
Boston, MA 02140
(617) 565-3394/FTS 835-3394
Messner, Chris
Policy Analyst
SAIC
8400 Westpark Drive
McLean, VA 22102
(703) 821-4808
Mitkus, Robert
Water Management Division
U.S. EPA, Region 3
841 Chestnut Building
Philadelphia, PA 19107
(215) 597-3420
Nessmith, Thomas
Chief, PPEB
U.S. EPA, Region 4
534 Courtland St.. SE
Atlanta, GA 30365
(404) 347-7109/FTS 257-7109
Ondich, Gregory
ORD/OEETD
U.S. EPA, HQ
401 M Street, SW
Washington, DC 20460
(202) 382-5747
Patton, Donald
Chief, Policy Office
U.S. EPA, Region 8
999 19th St., Suite 500
Denver, CO 80202-2405
(303) 293-1456/FTS 330-1456
Reed, Patricia
Booz-Allen and Hamilton
4330 East West Highway
Bethesda, MD 20814
(301) 951-2382
Appendix A
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Risler, Palma
Program Analyst
U.S. EPA, Region 2
26 Federal Plaza, Rm. 900
New York, NY 10278
(212) 264-7319
Roy, Manik (Nikki)
OSW, OSWER Waste Minimization
U.S. EPA, HQ
401 M Street, SW
Washington, DC 20460
(202) 382-4807
Schwartz, Amy
Community Relations Coordinator
U.S. EPA, Region 9
1235 Mission Street
San Francisco, CA 94103
(415) 744-1171/FTS 484-1171
Sharrow, Diane
Waste Minimization Staff
U.S. EPA, Region 5
230 S. Dearborn Street
Chicago, IL 60604
(312) 886-3730/FTS 353-4782
Simmons, Bob
Senior Policy Analyst
Pollution Prevention Division/HQ
999 18th St., Suite 500
Denver, CO 80202
(303) 294-7009/FTS 564-7009
Stein, Ellen
Environmental Engineer
U.S. EPA, Region 2
26 Federal Plaza, Rm. 1141
New York, NY 10278
(212) 264-1362/FTS 264-1362
Symmes, Brian
Pollution Prevention Division
U.S. EPA, HQ
401 M Street, SW
Washington, DC 20460
(202) 245-3590
Robertson, Lewis
Environmental Engineer
U.S. EPA, Region 6
1445 Ross Avenue
Dallas, TX 75202-2733
(214) 655-6790/FTS 255-6790
Schilling, Hank
Pollution Prevention Division
U.S. EPA, HQ
401 M Street, SW
Washington, DC 20460
(202) 382-4028
Shannon, Julie
Pollution Prevention Division
U.S. EPA, HQ
401 M Street, SW
Washington, DC 20460
(202) 382-2736
Shaver, Elizabeth M.
Pollution Prevention Program
U.S. EPA, Region 4
345 Courtland St., NE
Atlanta, GA 30365
(404) 347-7109/FTS 257-7109
Slotkin, Ron
Technology Transfer Staff
U.S. EPA, HQ
401 M Street, SW
Washington, DC 20460
(202) 382-7671
Swaine, Abigail
Pollution Prevention Program
U.S. EPA, Region 1
JFK Federal Building
Boston, MA 02146
(617) 565-4523/FTS 835-4523
Teeter, David
Hazardous Waste Policy Office
U.S. EPA, Region 10
1200 6th Avenue
Seattle, WA 98101
(206) 442-2871/FTS 399-2871
Appendix A
5
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Townsend, Laura
Pollution Prevention Coordinator
U.S. EPA, Region 6
1445 Ross Avenue
Dallas, TX 75052
(214) 655-2263/FTS 255-6525
Vendinello, Lynn
Pollution Prevention Division
401 M Street, SW
Washington, DC 20460
(202) 382-2602
Warm, David
Program Analyst
U.S. EPA, Region 8
999 18th Street, Suite 500
Denver, CO 80202
(303) 293-1621/FTS 330-1621
Wehmeyer, Alan
Waste Management Division
U.S. EPA, Region 7
726 Minnesota Ave.
Kansas City, KS 66101
(913) 551-7050/FTS 276-7050
Yoshii, Laura
Dep. Director, Waste Mgmt. Div.
U.S. EPA, Region 9
75 Hawthorne St.
San Francisco, CA 94105
(415) 744-1730/FTS 484-1730
Tuber, Stephen
Comptroller
U.S. EPA, Region 8
999 18th St., Suite 500
Denver, CO 80202
(303) 293-1472/FTS 330-1472
Verdon, Tina
American Management Systems
1777 N. Kent Street, 7th Floor
Arlington, VA 22209
(703) 841-6212
Wasserman, Cheryl
Compliance Policy & Planning
401 M Street, SW
Washington, DC 20460
(202) 382-7550
Woodman, Jocelyn
Pollution Prevention Division
U.S. EPA, HQ
401 M Street, SW
Washington, DC 20460
(202) 382-4418
Zanowick, Marie
RCRA
U.S. EPA, Region 8
999 18th St., Suite 500
Denver, CO 80202
(303) 293-1705/FTS 330-1705
Appendix A
6
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Directory of Pollution Prevention Contacts
HEADQUARTERS
The Office of Pollution Prevention at EPA Headquarters is responsible for all
policy development, program and grants management/oversight, resource
allocation, and inter-Agency/Department initiatives relating to EPA's
pollution prevention program.
Pollution Prevention Division
FTS Number
Jerry Kotas, Director
Claudette Campbell, Secretary
Alice Hill, AARP
John Cross, Deputy Director
Bob Simmons
James Boland
245-3557
245-3557
245-3557
245-4164
564-7009
382-4000
Prevention Integration Branch
John Atcheson, Chief 245-3575
Lenora Danger-field, Secretary 245-4164
Priscilla Flattery - Outreach, Communications,
Conference, Speaking, Calendar, Newsletter 382-4023
Deborah Hanlon - Training, Awards Program, Permits 382-2726
Jim Hayes - Industry, Technical Assistance, Corporate
Management Initiative 382-2689
Jim Edward - Federal Activties, Model Program 382-6920
Jocelyn Woodman - Industry Initiatives, Clearinghouse,
Enforcement 382-4418
Jackie Krieger - State Grants/Legislation 245-4172
Lena Harm - State Grants/Regional Coordinator 382-2237
Policy and Innovation Branch
Sharon Stahl, Acting Chief 245-4164
Yvonne Davis, Secretary 245-4164
Lynn Vendinello - Advisory Committee, Lead, Energy
Issues, Policy Statement 382-2602
Brian Symmes - Grants, International, Geographies,
Oil and Gas 245-3590
Dave Fege - Recycling 382-6920
Nancy Beach - List of Lists 475-7383
Julie Shannon - Strategy, Legislation 382-2736
Jim Craig - Data Collection, Analysis/Data, Targeting 245-4168
David Bassett - Clean Air, Energy, Transportation Issues 245-4167
Appendix B
1
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Office of Pesticides and Toxic Substances FTS Number
Susan Hazen 382-3667
Richard Hefter 382-2892
Office of Water
Vivian Daub - Water Policy Office 475-6790
Deborah Gillette - Enforcement and Permits 382-2656
Office of Research and Development
Morse Myles - Clearinghouse 475-7161
Gregory Ondich 382-5747
Office of Enforcement
Cheryl Wasserman 382-7550
REGIONS
The ten EPA Regions serve as the front line in implementing EPA's pollution
prevention program within their respective States.
Region I
AbbySwaine 835-4523
Susan Kulstad 835-3378
Mark Mahoney 835-3387
Region II
Palma Risler 264-7319
Region III
Nancy Grundahl 597-0355
James Hemby 597-8327
Region IV
Betsy Shaver 257-7109
Appendix B
2
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Region V
Linda Glass
Region VI
Lynda Carroll
Region VII
Alan Wehmeyer
Chet McLaughlin
David Flora
Region VIII
Don Patton
Sharon Childs
Region IX
Laura Yoshii
Kevin Dick
Liz Cameron
Region X
David Teeter
Claire Rowlett
FTS Number
886-1019
255-6525
276-7050
276-7666
276-7523
330-1456
330-1471
484-1730
484-2189
484-2190
399-2871
399-1099
Appendix B
3
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Draft Pollution Prevention Policy Statement - January 26, 1989
I. Background
EPA has made substantial progress over the last 18 years in improving
the quality of the environment through implementation of media-
specific pollution control programs. Not withstanding past progress,
there are economic, technological, and institutional limits on how
much improvement can be achieved under these programs, which
emphasize management after pollutants have been generated. As early
as 1976, EPA believed the nation could not continue to reduce threats
to human health and the environment while utilizing only better
methods of control, treatment, or disposal.
In practice, waste management activities by both the regulatory and
the regulated community have largely focused on treatment, control
and disposal as specified in EPA's major statutes and to a lesser extent
on recycling. Although each of these techniques is appropriate in a
comprehensive waste management strategy, government and industry
are beginning to realize that end-of-pipe pollution controls alone are
not enough. Significant amounts of waste containing toxic
constituents continue to be released into the air, land, and water
despite stricter pollution controls and skyrocketing waste
management costs.
There is increasing evidence of the economic and environmental
benefits to be realized by reducing waste at the source rather than
managing such waste after it is produced. Elimination of tons of
pollutant discharges can be combined with cost savings estimated
from the cost of pollution control facilities that did not have to be
built; reduced operating costs for pollution control facilities; reduced
manufacturing costs; and retained sales of products that might
otherwise have been taken off the market as environmentally
unacceptable.
Today's policy statement commits EPA to a program that reduces all
environmentally harmful releases. EPA's experience with its current
programs has shown that, notwithstanding the substantial gains that
have been made in limiting environmental pollution, media-specific
programs have some inherent limitations. Efforts to control or treat
pollutants subsequent to their generation or production can
sometimes result in transferes of these pollutants from one
environmental medium to another, where they may continue to
present a hazard. In addition, once these pollutants have been
produced or generated, some proportion of those releases will have an
impact on the environment, however effective the control or
management techniques. The preventive approach of today's policy
statement provides a way to more effectively respond to these
remaining problems.
Appendix C
1
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EPA believes that all sectors of our society must work together to
ensure continued environmental protection. EPA is committed to
working with individuals and organizations (both public and private) to
make source reduction and as a second preference, environmentally
sound recycling the major focus of future environmental protection
strategies. In particular, EPA believes that State and local
governments must play a primary role in encouraging this shift in the
environmental priorities of all sectors of industry and the public.
Some programs within EPA have already adopted measures to promote
source reduction and recycling. For example, the Office of Water has
adopted effluent guidelines that have resulted in flow reductions and
product substitutions. The rapid phasing down of lead in gasoline by
EPA's Office of Air and Radiation Programs is another attempt to
reduce pollution at the source. Nevertheless, much of the past focus
in these programs has been on pollution control rather than pollution
prevention. It is necessary at this time to reassess EPA's programs in
light of today's policy statement and redirect them accordingly.
The term "waste minimization" which EPA has previously used in
reference to source reduction and recycling activities in its hazardous
waste program, has been replace in today's policy statement by the
phrase "pollution prevention." Through eliminating a term that may
be perceived as closely tied to RCRA, EPA is emphasizing that the
policy has applicability beyond the RCRA hazardous waste context.
EPA stresses that the policy focuses primarily on the prevention of
pollution through the multi-media reduction of pollutants at the
source. In addition, in order to obtain additional benefits of avoiding
releases to the environment, EPA's pollution prevention program
secondarily promotes environmentally sound recycling.
tt EPA's Pollution Prevention Policy
EPA's proposed policy encourages organization, facilities and
individuals to fully utilize source reduction techniques in order to
reduce risk to public health, safety, welfare and the environment as a
second preference to use environmentally sound recycling to achieve
these same goals. Industrial source reduction can be accomplished
through input substitution, process modification, improved
houskeeping, and on-site closed loop recycling. Although source
reduction is preferred to other management practices, the Agency
recognizes the value of environmentally sound recycling, and is
committed to promoting recycling as a second preference, above
treatment, control and disposal.
EPA believes pollution prevention through source reduction and
environmentally sound recycling is highly desirable, and that as a
Nation there are many opportunities in source reduction and recyling
that we have not yet pursued. However, we recognize that, while
Appendix C
2
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there is still much progress to be gained, the extent to which we can
prevent pollution also has limitations and that safe treatment, storage
and disposal for pollution that couldn't reasonably be reduced at the
source or recycled will continue to be important components of an
environmental protection strategy. Source reduction and recycling
will not totally obviate the need for or the importance of these
processes. Individuals as well as industrial facilities or organizations
can practice source reduction and recycling through changing their
consumption or disposal habits, their driving patterns and their on-
the-job practices. EPA believes that developing and implementing a
new multi-media prevention strategy, focused primarily on source
reduction and secondarily on environmentally sound recycling, offers
enormous promise for improvements in human health protection and
environmental quality and significant economic benefits.
HL Development of EPA's Multi-Media Pollution Prevention Program
EPA has initiated developpment of a comprehensive pollution
prevention program to implement this pollution prevention policy
throughout the Agency programs, whether they affect air, land, surface
water, or ground water. EPA has established a Pollution Prevention
Office which together with the Agency's media-specific offices will
develop and implement this program. EPA will develop an overall
Agency pollution prevention strategy, as well as coordinate strategies
among EPA's program and regional offices. An important emphasis of
these strategies will be on educational, technical assistance and
funding support to make it easier to build these programs into the
public and private sectors. An Advisory Committee of senior Agency
managers will help direct EPA's pollution prevention program and will
assure the participation of the entire Agency in this important
mission. As part of this program, EPA will establish mechanisms for
avoiding or mitigating the generation and cross-media pollution
prevention program will focus on several key components. These
include:
The development of institutional structures within each of EPA's
media-specific and regional offices to ensure that the pollution
prevention philosophy is incorporated into every feasible aspect of
internal EPA decisionmaking and planning;
The support of State and local pollution prevention programs.
EPA believes that State and local agencies are more aware of the
problems facing the commercial or manufacturing industries or
consumers, than the federal government. Indeed, a few States have
already formally recognized the importance of multi-media pollution
prevention. One of EPA's primary goals is to help States develop their
own pollution prevention programs;
Appendix C
3
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The development of an outreach program targeted at State and
local governments, industry and consumers, designed to effect a
cultural change emphasizing the opportunities and benefits of
pollution prevention;
The creation of incentives and elimination of barriers to
pollution prevention;
The development of a multi-media clearinghouse to provide
education and technical information. This includes the support of
research, development and demonstrations necessary to provide
relevant data; and
The collection, dissemination and analysis of data for the
purpose of evaluating national progress in multi-media pollution
prevention.
EPA believes that the development of a comprehensive multi-media
pollution prevention, policy offers enormous promise for
improvements in human health protection and environmental quality.
Because the focus of pollution prevention is on greater efficiency in
the use of materials and processing of products, its implementation
could additionally result in significant economic benefits.
There are significant opportunities for industry to reduce the
generation of waste at the source through cost-effective changes in
production, operation and raw materials use. Such changes offer
industry substantial savings in reduced raw material, waste
management and liability costs as well as help protect the
environment.
There are varying views among representatives of industry, public
interest groups, state and local governments and others over the role
of recycling in pollution prevention. Thes Agency believes that source
reduction (including closed-loop recycling) can reduce risk and
should be implemented in a cost-efficient manner. It is generally
preferred over other management approaches. The Agency also
believes that out-of-loop and off-site recycling, when properly
conducted, also offers the potentional for significant economic
benefits and reduced risk. With the publication of this proposed
pollution policy, the Agency would like to specifically request
comment on the role of environmentally sound recycling in the
pollution prevention program. Other comments on this policy, and on
the steps necessary to implement it effectively are invited.
Appendix C
4
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xvEPA
United States
Environmental Protection
Agency
Office of Pollution Prevention
Washington, DC 20460
Summer 1990
Pollution Prevention
Fact Sheet
Setting Up a Pollution
Prevention Program
Where Do
I Start?
Program
Elements
Industry, service businesses, municipalities, and other institutions are
finding that pollution prevention programs can result in improved
regulatory compliance, reduced costs for pollution control and waste
disposal, improved employee safety, and reduced liability associated
with the management of hazardous materials and wastes. In other
words, a pollution prevention program is economically as well as
ecologically sound, and can be implemented by any organization.
A Pollution Prevention Program is defined as an organized,
comprehensive, and continual effort to systematically reduce or
eliminate pollution and wastes.
In June 1989, EPA published Draft Guidance to Hazardous Waste
Generators on the Elements of a Waste Minimization Program to
assist hazardous waste generators in complying with RCRA
certification requirements. The elements outlined in the guidance
can also be used in the development of a pollution prevention
program:
(1) Top management support is needed to ensure that pollution
prevention becomes an organizational goal. To demonstrate such
management support, use techniques such as:
~ Written company policy on pollution prevention
Specific goals and objectives for reducing waste stream
volume or toxicity
Designating program coordinators
- Publicizing and rewarding successes
Employee training.
(2) Identify and characterize wastes and pollutants -- in terms of
the source of generation, why each waste is produced, the type and
quantity generated,, its toxicity, and all possible routes of exposure.
Appendix D
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Printed on-Recycled Paper
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This will help in prioritizing prevention efforts and identifying key
personnel that can assist in implementing the program.
(3) Periodic pollution prevention assessments or environmental
audits help to ensure that pollution prevention opportunities
continue to be sought and solutions implemented.
(4) A cost allocation system. Departments and managers should be
charged "fully-loaded" pollution control and waste management
costs. Labor costs, liability, regulatory compliance, disposal and
oversight costs should all be included.
(5) Encouragement of technology transfer. Many successful
techniques have been documented that may be applicable to your
facility. Information can be obtained from federal and state
agencies, universities, trade associations, and other firms.
(6) Program evaluation. Conduct periodic reviews of program
effectiveness to provide feedback and identify potential areas for
improvement. Has the pollution prevention ethic become a
significant part of the way you do business? Have all opportunities
to prevent pollution been explored?
Where Do A useful, ongoing source of information is EPA's Pollution
I Go Next? Prevention Information Clearinghouse (PPIC), which offers a
computerized network for information exchange, a hotline, and a
document repository. To reach the Clearinghouse, write: PPIC,
Science Applications International Corp., 8400 Westpark Drive,
McLean, VA 22102, or call: 1-800-424-9346 (or 202-382-3000 in the
Washington, D.C. area).
Another next step would be to consult a manual for conducting
pollution prevention assessments. Such manuals include:
EPA Waste Minimization Opportunity Assessment Manual. EPA/625/7-88/003. July
1988. Hazardous Waste Engineering Research Laboratory, U.S. EPA, 26 W.
Martin Luther King Drive, Cincinnati, OH 45268.
New York State Waste Reduction Guidance Manual March 1989. New York State
Department of Environmental Conservation, Division of Hazardous Substances
Regulation, 50 Wolf Road, Albany, NY 12233-7253.
Profiting from Waste Reduction in Your Small Business. 1988. Alaska Health
Project, 431 West 7th Ave., Suite 101, Anchorage, AK 99501, 907-276-2864.
Waste Minimization: Manufacturers' Strategies for Success. 1989. National
Association of Manufacturers, 1331 Pennsylvania Ave. NW, Suite 1500, Washington,
D.C. 20004-1703. S19.95 NAM Mcmbers/S29.95 Non-Members.
A Citizen's Guide to Promoting Toxic Waste Reduction. 1990. INFORM, 381 Park
Ave. S. New York, NY 10016. S15.00 plus S2.50 shipping.
Appendix D
2
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United States
Environmental Protection
Agency
Office of Pollution Prevention
Washington, DC 20460
Summer 1990
&EPA
Pollution Prevention
Fact Sheet
EPA's Pollution Prevention
Incentives for States
Goals
1988/89
Awards
1989/90
Awards
States have been at the forefront of the pollution prevention
movement, providing a direct link to industry, local governments,
and consumers. Through grants to states, EPA aims to enhance
state capabilities to demonstrate innovative and results-oriented
programs and to assist states in implementing a multimedia
prevention approach.
In fiscal year 1988, EPA's Office of Pollution Prevention awarded
over $3.9 million in multi-media state grants to 13 states and one
regional association of waste management officials. Awards ranged
from $197,000 to S300,000 over a two to three year period. Grant
recipients include Alaska, Idaho, Indiana, Kentucky, Louisiana,
Massachusetts, Michigan, Mississippi, New Jersey, New York, North
Carolina, Rhode Island, Texas, and the New England Waste
Management Officials Association. (See inside for details.)
A second round of grants was awarded in May 1990 totalling $7
million; 25 state-based initiatives have been funded to further
pollution prevention efforts across the country. Projects are being
funded in all 10 EPA regions, in the following locations: California,
Colorado, District of Columbia, Delaware, Georgia, Iowa (2),
Illinois, Indiana, Massachusetts, Maine, Michigan (2), Minnesota,
Missouri, Nebraska, New Jersey, New York, Oklahoma,
Pennsylvania, Tennessee, Virginia, "Washington, West Virginia, and
American Samoa. The awards range from 5125,000 to 5300,000 for
projects lasting up to three years. States are required to contribute
at least 10 percent of the total cost of each project in their
jurisdiction. (See inside for details.)
Appendix D
3
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1988/89 Awardees
ALASKA Department of
Environmental Protection/
Alaska Health Project
IDAHO Department of
Health & Welfare/Division
of Environmental Quality
INDIANA Dept. of
Environmental Management
KENTUCKY Dept. of
Environmental Protection
LOUISIANA Dept. of
Environmental Quality
MASSACHUSETTS Dept. of
Environmental Management
MICHIGAN Department
of Natural Resources
MISSISSIPPI Department
of Natural Resources
NEWMOA (New England
Waste Management
Officials Association)
NEW JERSEY Hazardous
Waste Facilities
Siting Commission
NEW YORK Department of
Environmental Conservation
NORTH CAROLINA Dept. of
Natural Resources &
Community Development
RHODE ISLAND Dept. of
Environmental Management
TEXAS Water Commission/
Hazardous & Solid Waste Division
Two-year effort to establish an integrated prevention
program, including tech transfer/assistance, audits,
curriculum development, pilot waste reduction programs for rural
Alaska.
Two-year program to establish state-sponsored, county-
managed recycling program for industrial wastes; establish
waste exchange service.
Three-year program to create an integrated technical
assistance and enforcement program.
Three-year program to compile a single, cross-media
risk and release database, expand waste minimization
programs, pursue other cooperative projects.
Research to define state problems, target Industries,
and establish performance measures (3 year program).
Grant to expand existing technical assistance. Pilot project
includes training for interns, state inspectors; workshops; financial
feasibility model for company managers. (3 yrs.)
Three-year "Source Reduction Intern Program;" focus will
be on small/medium sized electroplaters, automobile assembly and
component part plants.
Two-year program offering outreach, tech assistance,
demonstrations to small/medium sized industries.
Regional project to establish centralized clearinghouse &
database, provide tech assistance to states, and develop
source reduction options for wastestreams destined for resource
recovery systems.
Two-year tech assistance program, including methods
development research for targeting priority industries and
development of PC software for tracking raw products, waste
generation, and waste management costs.
Three-year program to hire additional staff, provide
training, conduct workshops, establish clearinghouse, etc,, with aim
of reducing waste discharges.
Two-year effort to augment current extensive program
with waste reduction information management system, to
serve as demonstration project for other states.
Technical assistance program including in-plant audits,
re-audits, documentation of case studies, training {3 yrs).
Development & implementation of Waste Minimization
Recycling Program (2 years, 9 months).
Appendix D
4
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1989/90 Awardees
AMERICAN SAMOA
Environmental Protection Agency
CALIFORNIA Department of
Health Services
COLORADO Department of
Health
DELAWARE Dept. of Natural
Resources & Environmental Control
D.C; Metropolitan Washington
Council of Governments/Dept. of
Environmental Programs
GEORGIA Department of
Natural Resources
ILLINOIS Environmental
Protection Agency
INDIANA: Purdue University,
Division of Sponsored Programs
IOWA Department of
Natural Resources
IOWA Waste Reduction
Center
MAINE: Univ. of Maine,
Dept. of Chemical Engineering
MASSACHUSETTS Dept. of
Environmental Protection
MICHIGAN Department of
Education
MICHIGAN State University,
Cooperative Extension Service
MINNESOTA Office of
Waste Management
Project to promote public awareness of proper waste
disposal practices, promote aluminum can recycling,
conduct waste oil demonstration project (3 years).
Two-year interagency effort to develop a comprehensive
training program to promote pollution prevention.
Two-year project with educational, data-gathering,
training components; examination of urban development, land use,
transportation issues.
Two-year effort to develop and implement Pollution
Prevention Program, overseen by Advisory Committee.
Public/private partnership to prevent pollution from
vehicle emissions, demonstrate impacts of using alternative
fuels in buses (3 years).
One-year project to establish multi-media source reduction
and recycling program, provide training tech assistance.
One-year project to implement Toxic Pollution Prevention
Act, including targeting prevention opportunities, sponsoring pilot
projects, reviewing facility plans.
Three-year effort focusing on point source agricultural
pollution prevention, to include training for Extension Service
agents, an inventory of current practices and technologies, an
Advisory Council, and possible establishment of farm chemical
"clean-up days."
Three-year project focusing on large quantity generators,
including Governor's Award program, procurement directives,
retired engineer program, incentive grants.
Three-year program for small quantity generators,
providing technical assistance, expanded information base.
Three-year educational program for groups dealing
with the public or students.
Assistance to ongoing projects including cross-media
permitting, inspection, enforcement, and data-gathering; developing
regulatory toxics use reduction planning requirements (2 years).
Project focusing on multi-media pollution prevention at
educational facilities (1 year, 9 months).
Development of 100-hour course for waste assessors
(Michigan Waste Assessment Training Project) (U years).
Development and evaluation of risk screening and priority
ranking method for hazardous air emissions (2 years).
Appendix D
5
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1989/90 Awardees
(continued)
MISSOURI Department of
Natural Resources
NEBRASKA: University of
Nebraska - Lincoln
NEW JERSEY Department of
Environmental Protection
NEW YORK: Western NY Economic
Development Corp./Erie County Dept.
of Environment & Planning
OKLAHOMA Department of
Health
PENNSYLVANIA Center for
Hazardous Materials Research
TENNESSEE Department of
Health and Environment
VIRGINIA Department of
Waste Management
WASHINGTON Department
of Ecology
WEST VIRGINIA Division of
Natural Resources
Three-year effort focusing on point source agricultural
pollutants, with demonstration projects at bulk fertilizer and
pesticide dealerships.
Three-year program to assess waste streams associated
with specific commercial establishments in rural areas, develop
pollution prevention office.
Expansion of Office of Pollution Prevention to coordinate
existing activities and target industries; development of guidance
package for preparing prevention plans (3 years).
Expansion of existing Erie County Prevention Program to
incorporate multi-media pollution prevention policy and
serve as a model to other counties (3 years).
Three-year funding to support coordination of prevention
activities, education, technical assistance, consideration of economic
incentives.
Model prevention program in university operations;
expansion of existing activities to targeted industries including
fabricated metal, machinery, printed circuit board manufacturers,
and chemical products (2 years).
One-year project to include training of retired engineers,
teleconferencing and videos, industry-specific education programs,
and workshops for regulatory personnel
Two-year program to form interagency team of "internal
champions" to promote multi-media prevention and identify
industrial opportunities for prevention (2 years).
Two-year project to obtain baseline data for measuring
waste reduction and recycling, and to increase coordination on
pollution prevention programs and issues.
Public-private partnership to facilitate voluntary state-
wide program modelled after N1CS' "Scorecard" reporting system
for chemical producers and processors (3 years).
For Further
Information
For further information on the multi-media grants program, contact
Jackie Krieger in EPA's Office of Pollution Prevention, (202) 245-
4164.
Appendix D
6
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v^EPA
United States
Environmental Protection
Agency
Office of Pollution Prevention
Washington, DC 20460
Summer 1990
Pollution Prevention
Fact Sheet
Pollution Prevention
Training and Education
Resource
Guide
Video
Newsletter
An important goal of EPA's Pollution Prevention Program is to
ensure that pollution prevention training and education are
available to government, industry, academic institutions, and the
general public. Training and education are needed to help
institutionalize prevention as the' strategy of choice in ail
environmental decision-maJdng and protection activities.
EPA's Office of Pollution Prevention has developed a resource
guide, Pollution Prevention Training Opportunities in 1990. The
guide describes the types of training courses, workshops, and
seminars being offered in each state and provides contact names
and-addresses. Other sections of the guide list available instruction
manuals, opportunity assessment materials, fact sheets, videos, and
state and EPA contacts on pollution prevention. Copies of the
guide may be obtained through the Pollution Prevention
Information Clearinghouse, SAIC, 8400 Westpark Drive, McLean,
VA 22102, Tel: 1-800-424-9346 (or 202-382-3000 in the Washington,
D.C. area).
EPA's 30-minute documentary on pollution prevention is intended
to raise awareness of pollution problems and solutions. The video
highlights case studies of successful pollution prevention programs.
Available, along with other videos, through the Pollution Prevention
Information Clearinghouse.
Pollution Prevention News contains articles and editorials on
pollution prevention topics, reports on EPA activities related to
pollution prevention, information on new technologies and
approaches, a calendar of events, and special features on people
and places in the news. To be placed on the mailing list, write:
Pollution Prevention News, U.S. EPA, 401 M Street SW (PM-219),
Washington, DC 20460.
Appendix D
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Conferences EPA cosponsors pollution prevention conferences and workshops
throughout the year with trade and other professional associations
and states. Conferences are listed in the Calendar section of
Pollution Prevention News and in the Pollution Prevention
Information Exchange System (PIES) of the Pollution Prevention
Information Clearinghouse. (For more information on PIES, call
the PPIC Technical Support line at 703-821-4800.)
Courses
The Office of Pollution Prevention is developing specialized courses
designed for government employees and industry. The courses will
be available through the EPA Regional Offices starting in 1991.
Course topics will include:
- Pollution Prevention Orientation
Pollution Prevention for Permit Writers
Industrial Waste Pollution Prevention for Inspectors.
Pollution Prevention for Regulation-Writers
Speakers'
Bureau
The Office of Pollution Prevention is developing a speakers' bureau
to assist in pollution prevention training and technical assistance for
government and industry groups.
For More
Information
For more information, call the Office of Pollution Prevention
Training Coordinator at 202-245-4164.
Appendix D
-------
U.S. EPA Pollution Prevention Information Clearinghouse
(PPIC)
In order to promote pollution prevention. EPA has established the
Pollution Prevention Information Clearinghouse (PPIC). a
clearinghouse dedicated to reducing industrial pollutants through
technical information transfer, education, and public awareness. The
PPIC contains technical, policy, programmatic, legislative, and
financial information and works through four information exchange
mechanisms:
Repository -- A hard copy reference library containing the
most up-to-date information on pollution prevention.
PIES A computerized national and international network
accessible to anyone with a personal computer (PC) and
modem. PIES provides a forum for exchange of questions and
ideas and contains pollution prevention data bases and
document ordering functions.
Hotline ~ A free telephone service to answer questions, make
referrals, and provide a link to PIES for users without access to
a PC.
RCRA/Superfund Hotline 800/424-9346
Small Business Ombudsman Hotline 800/368-5888
PPIC Technical Assistance 703/821-4800
Outreach Efforts ~ Information packets containing general
and industry-specific materials on prevention opportunities
and workshop training sessions.
Through PPIC, individuals in Federal, State, and local government;
industry; academia; public/private institutes; and public interest
groups can access the latest pollution prevention technology and
program developments.
For more information on any aspect of the PPIC, call:
Myles E. Morse, Office of Environmental Engineering and Technology
Demonstration (202) 475-7161; FTS 475-7161, or Priscilla Flattery.
Pollution Prevention Office, (202) 245-3557; FTS 245-3557.
Appendix E
1
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